Ken J. Buttenham, "Are you Ready for the Upstream Loan Rules?", Canadian Tax Journal, (2013) 61:3, 747-68

Summary Under
Tax Topics - Income Tax Act - Section 90 - Subsection 90(14)
Application to cash-pooling arrangements (p. 755)

…In practice, it may be challenging for taxpayers and the CRA to determine the correct...

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Summary Under
Tax Topics - Income Tax Act - Section 90 - Subsection 90(6)
Relationships tested when upstream loan arose (pp. 761-2)

The application of subsection 90(6) and other upstream loan rules is based on the...

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Summary Under
Tax Topics - Income Tax Act - Section 90 - Subsection 90(9)
Uncertainties under s. 90(9) (p. 763)

The operation of subsection 90(9) raises a host of unanswered questions and is probably what will create...

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